Alexander v. Toyota Motor Sales, U.S.A.
123 So. 3d 712
La.2013Background
- Plaintiff bought a 1995 Toyota Corolla from A-Quality Auto Sales, which had acquired it from Lakeside Toyota after a trade-in.
- Plaintiff was injured in a later accident and alleged Lakeside failed to attach the revised airbag warning label.
- Lakeside moved for summary judgment, contending it owed no duty to warn; the trial court granted summary judgment.
- Court of Appeal majority reversed, rejecting privity-based bar and finding a duty to warn could exist; dissenters agreed otherwise.
- Lakeside filed a writ petition seeking reversal; the issue centered on federal labeling requirements and state-law product liability duty.
- The Supreme Court granted Lakeside’s writ, held no federal duty to install revised labels on pre-1997 vehicles, and affirmed summary judgment for Lakeside under the Louisiana Products Liability Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Duty to warn under federal rule | Alexander contends Lakeside owed a warning duty under FHSA-related federal rule to pre-1997 vehicles. | Lakeside argues NHSA rule did not require revised labels for 1995 vehicles; no federal duty. | No federal duty; summary judgment affirmed. |
| Duty under Louisiana Products Liability Act (non-manufacturer seller) | Seller who knew of defect and failed to warn should be liable to foreseeable users. | Elements not proven; lack of defect and attenuated nexus defeat liability under LPLA. | Elements not proven; no duty under LPLA; summary judgment maintained. |
| Policy and scope of duty to warn in Meany framework | Policy favors consumer protection; duty should extend to the seller as a foreseeable warning conduit. | Extending duty would broaden dealer liability excessively and undermine Meany factors. | Policy considerations do not support extending duty; no duty recognized in these facts. |
Key Cases Cited
- Media Production Consultants, Inc. v. Mercedes-Benz of North America, Inc., 262 So.2d 377 (La. 1972) (privity and duty-to-warn concepts in product liability)
- Meany v. Meany, 639 So.2d 229 (La. 1994) (duty in tort examined via policy considerations)
- Reaux v. Deep South Equipment Co., 840 So.2d 20 (La.App. 4 Cir. 2003) (non-manufacturer seller liability under LPLA prerequisites)
- Gammill v. Invacare Corp., 2 So.3d 557 (La.App. 4 Cir. 2008) (duty to warn and privity considerations in product liability)
- Alexander v. Toyota Motor Sales, U.S.A., Inc., 110 So.3d 668 (La.App. 4 Cir. 2013) (sellers' duty to warn in third-party sale context)